1. Of the instant lawsuit, the part regarding the claim for the revocation of the collection disposition as of August 3, 2012 and the collection disposition as of August 6, 2014 are all applicable.

1. Details of the disposition;

가. 원고는 2011. 8. 26.경 상호를 ‘B’(이후 상호가 ‘C’로 변경되었다)로, 개업일을 2011. 8. 29.로, 사업장 소재지를 자신의 주민등록지인 ‘인천 부평구 D빌라 4동 101호’로, 업종을 ‘건설업, 인테리어(샷시공사)’(이하 ‘이 사건 사업’이라 한다)로 하여 사업자등록(사업자 등록번호 : E)을 하였다가 2014. 10. 31. 폐업신고를 하였다.

B. Around August 3, 2012, the Plaintiff filed a global income tax return for the year 201, but did not pay the global income tax. On August 3, 2012, the Defendant notified the Plaintiff of the payment of global income tax amounting to KRW 99,272 (including additional tax) (hereinafter “instant disposition”), which led to the Plaintiff on August 9, 2012.

C. On May 19, 2014, the Plaintiff filed a return on KRW 2,071,357 of the global income tax for the year 2013, but did not pay it. On August 6, 2014, the Defendant notified the Plaintiff of the payment of global income tax amounting to KRW 2,111,748 (including additional tax) (hereinafter “instant disposition”), and this reached the Plaintiff on August 11, 2014.

On November 3, 2014, the Defendant imposed KRW 1,055,000 on the Plaintiff for interim prepayment of global income tax for the year 2014.

(hereinafter referred to as “third disposition”). (e)

The Plaintiff filed a petition for a trial against a disposition on January 19, 2015, but the Tax Tribunal dismissed the petition for a trial against a disposition on April 1, 2015 on the ground that the petition for a trial against a disposition on April 2, 2015 does not constitute an appeal litigation, and decided to dismiss the petition for a trial against a disposition on the third disposition.

[Ground of recognition] The fact that there is no dispute, Gap evidence 2, Eul evidence 1 through 5, 6, 9 (including all family evidence attached with a serial number), the purport of the whole pleadings and arguments

2. Determination as to whether the part concerning the revocation of the first and second dispositions among the instant lawsuit is legitimate

A. The Plaintiff is the actual business operator of the instant business, and the Plaintiff merely lent its business registration name, and thus, the first and second dispositions violate the principle of substantial taxation, and seek its revocation.